ML20078L624
| ML20078L624 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 05/12/1983 |
| From: | Graves C DUKE POWER CO. |
| To: | |
| Shared Package | |
| ML20078L617 | List: |
| References | |
| FOIA-83-434 NUDOCS 8310240017 | |
| Download: ML20078L624 (44) | |
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UNITED STATES OF A! ERICA NUCLEAR REGULATORY COMMISSION BETOP.E THE ATOMIC SAFETY AND LICENSING BOARD
%N RE: )
)
DUKE POWER COMPANY, et al. ) Docket Nunbers l(CataubaNucienrStation, ) 50-413 Units 1 and 2 ) 50-414
','s ,
May 12, 1983 3:30 P.M.
DEPOSITION OF:
CLYDE WILLIAM GRAVES 8310240017 830810 PDR FOIA
( AHLERS83-434 PDR
/} 'l' Evelyn llerger Associates STENOTYPE REPORTING SERVICE P.O. BOX 19444
@MARN@TTE. N ORTH CAROLIN A 28219
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L A WY E R'S NOTES Page Line t'
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E. . . 2 1 APPEARANCFS:
I 2 ROBERT GUILD, ESQUIRE Charleston, South Carolina 3 ~
Counsel on Behalf of Intervenor Palnetto Alliance ,
4 Incorporated 5 DEBEVOISE &.LIBERMAN, ESQUIRES Washington, D.C.
6 BY: J. Michael McGarry, III, Esquire e.nd Anne W. Cottinghan 7
Albert V. Carr, Jr., Esquire 8 Rcnald L. Gibson, Esquire Charlotte, North Carolina 9 ,
- Counsel on Behalf of Applicant Duke Power Company 10 11 ALSO PRESENT:
12 Roger W. Ouellette Duke Power Company
- 13 Michael F. Lowe 14 Palmetto Alliance, Incorporated 15 Lee Ann Kornegay Electronic Recorder 16 Palmetto Alliance; Incorporated 17 18 INDEX 19 Witness Direct Cross Redirect Recross _
20 Clyde William Graves 3 21 22 23 24 l
25 EVELYN BERGER ASSOCI ATES. S1ENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROLtNA L
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- 3 1 The Deposition of Clyde William Graves is taken at the 2 offices of Duke Power Cor:.pany, Char 1ctte, North Carolina, on 3 this the 12th day-of May, 1983, in the presence of Robert Guild, 4 Counsel on Bchalf of Paltetto Alliance, Incorporated; and J.
5 Michael McGarry,- III, Anne W. Cottingham, Albert V. Carr,Jr.,
6 and Ronald L. Gibson, Counsel on Behalf of Duke Power Company.
7 It is agreed that Lynn B. Gilliam, Notary Public in 8 and for the State of North Carolina, may take said deposition 9 in machine shorthand and transcribe' the same to typewriting.
10 !!R. McGARRY: I would like this transcript to reflect 11 that the Stipulation referred to in the Deposition of fiary Birch 12 controls with respect to the taking of the Deposition of I'r. Graves.
13 Applicant's ce=nents concerning Notice and acconnodations 14 to Palmetto Alliance as contained in I*ary Birch's Deposition are 15 applicable to this Deposition.
16 Lastly, co= rents concerning docunents in Mary Birch's 17 Deposition should be atended to reflect that in this Deposition 18 a copy of the FSAR has been nade available in this room; and we 19 have discussed other documents Mr. Guild wishes to have, and we 20 are trying to accotncdate that request.
21 t
22 CLYDE WILLIAM GRAVES, '
23 having been first duly sworn to tell the truth, was er.anined 24 and testified as follows:
25 EVELYN BERGE R ASSOCIATE S. STENOTYPE REPORTING SERvtCE. CHARLOTTE. NORTH CAROLINA
- r. ^."TZ: ;- acu I
g DIRECT EXAMINATION 2
BY MR. GUILD:
~
3 Q Mr. Graves, my name is Bob Guild. I am Counsel for 4
Palmetto Alliance as an Intervenor. I understand you have been 5
identified as the person knowledgable to respond to questioning 6
concerning the question of qualifications at the station. Do I
you understand that?
8 A. Sure do.
9 4 Please, I would like to be informal, but you need to 10 state yes or no for an answer so that the court reporter can Il pick you up.
12
, I will ask you a series of questions, and these ques-I3 tions are for purposes of my client ls_ gathering information,in I4 support of our Contention.
15 If you do not understand a question I ask or are not 16 21 ear in the use of terms or the way I phrase it, please stop II me and ask and we will see if we can clarify. Otherwise, I will I8 assume that you understand the question and that your answer I9
- 'eflects that understanding.
90 I will show you a copy of the Company's response to
l one of our sets of interrogatories on this subject (indicating).
22 Can you identify that docurent?
23 MR. McGARRY: Road the title into the Record.
.y THE UITNESS: " Responses to Palmetto Alliances'
- 0 Interror otorien mi P"T m r2 Yn *~'"c" "
Evf LYN BE 9GER ASSOCIATES. STENOTTPE REPORTING SE RvlCE CMARLOTTE. NORTM CAROUNA
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- GRAVES - Direct -
5 1 BY MR. GUILD:
2 C Mr. Graves, you participated in producing the infor-3 mation for the answers on Contention 8. Let ce show you in the 4 back, I think the document attached to this response includes 5 your Affidavit. Is that your signature (indicating)?
6 A Yes.
7 Q And you did assist in preparing information to respond 8 to these interrogatories?
9 A yes, 10 Q Now, the Contention that is the subject of these ques-11 biens has been admitted by the Atomic Safety and Licensing Board 12 End numbered Contention 8. Let me show you Page Five of that s
13 document (indicating) and read that to yourself, if you would, 14 Tr. Graves, at this time.
15 A Okay, just the first part?
- 16 4 Yes, sir; that is it. Have you seen that Contention l
l 17 ']efore?
l 18 A Yes, I have.
19 Q If you would, I want to ask you to identify your pre-l 20 bent position with the Company and briefly describe your work 21 history with them and relevant history before that, including 22 pny professional training or academic training that you have.
23 A I am the Superintendant of Operations at Catawba 24 l!uclear Station. Previous work history is I have been with 25 Juke Power Company 18 years the 24th of this month.
EvEtvN eE RGER AS$OCI ATES. STENOTYPE REPO4 TING SE nvlCE. CHARLOTTE. NORTH Camouha
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' I I've got -- during the time I spent with Duke Power 2
Company, I spent four years at Plant Allen -- I transferred from 3 Allen to Oconee Nuclear Station and participated in the start-4 up of Units One and Two and functional testing on Unit Three.
5 In 1974 I transferred to McGuire and participated in 6
preoperational testing there until 1978. At that tine I was 7
promoted to Superintendant of Operations at Catawba Nuclear 8
Station.
9 I have been at Catawba for approximately five and a-10 half years. During my assignment at Catawba I spent one year
" at the Institute of Nuclear Power Operations; and initally help-12 ing the Evaluation and Assistance Division get orders and begin I3 the evaluation of nuclear power' plants across the country.
" I spent approximately two weeks in March, April, 1979 ,
15 in the recovery of the accident at Three Mile Island.
- I have also had some temporary assignments to the Gen--
II eral Office working in the Project and Licensing Division under Mac Getty, who reported to the Project and Licensing Engineer up there.
20 4 Before you joined Duke Power Conpany?
21 A I was in the United States Navy for four years.
oo i ~
Q Did you have work experience with the Navy relevant i 03
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to your job now?
i o#
A It was relevant; it wasn't nuclear experience, but it 25 i was relevant power plant experience.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA
(? .
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1 4 What sort was that , Mr. Graves?
2 A Machinist Mate type work, boiler type work en the 3 USS Independence, an attack air craft carrier.
4 4 That was a steam power plant?
5 A Yes, sir.
6 4 All right, sir; what was the year that you spent with 7 HiPO, Mr. Graves?
8 A Nineteen eighty.
9 4 Where were you working?
10 A In Atlanta, that was the home base.
11 4 Mr. Graves, if you would, give me an overview of the 12 ? resent training program for control room personnel at the 1
13 Jatawba Nuclear Station that essentially takes people to the 14 ?oint where they come to the company and provides them with what 15 fou believe to be training experience, instruction sufficient 16 -;o perform control room responsibilities under aev,ual operating 17 conditions.
18 A That is quite an extensive program. Basically they 19 participate in basic and advanced training; and that program 20 is described in detail in the FSAR.
21 Q If you would make a reference to that and if in the 22 ?uture, if there are answers to questions that are covered 23 cdequately by reference to a document, that would save us alot 24 of time.
25 The entire document sits right behind you. Let's see
! EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SthvtCE CHARLOTTE. NORTH CAROLINA 11
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. GRAVES - Dir2ct A
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if we can pull out that section. Mr. Graves, if you would give 2
to the reference to the appropriate page number and FSAR --
3 A The training program is described in Section 13 2'of-4 bhe FSAR and begins on Page 1 3.2 - 1. And in the FSAR is also 5
- entained the experience levels of a number of key Catawba Station 6 :3ersonnel.
7 4 Can you direct ny attention to the portion of that
\
8 i iocument where that infornation is contained? \
9 A Sure, it is Section 13 " conduct of operations".
10 4 Mr. Graves, what is the latest revision, the most 11 current revision, to that document that contains the most updated
'2 f.nformation concerning qualifications of Catawba Station people?
13 A I assume this manual (1'ndicating) is updated; but let' a 14 hake a quick look. It is Revision Seven.
15 4 Is there a date for that revision that appears on 16
?, hose pages, or is available7 17 A I don't really know.
18 Q Mr. Graves, what is your understanding of the tern 19
" Hands-On Operating Experience"?
20 A I believe it is described in the interrogatories. As 21
- n. matter of fact, I don't think we described it. I think that 22 Bob did.
23 MR. GUILD: Yeah, I certainly have; and it is a 24 itern that we have employed in our contentien, Mr. Graves.
25 BY MR. GUILD: ,
EVELYN SERGER ASSs ' ATE S. S?E*eOTYPE REPORTING SE RvlCE. CH
- RLOTTE. NCRTH CAROUN A
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GRAVES - Direct 9 4
1 4 But what I'm interested in is if you have en under-2 standing of that term and what it is.
3 A l',y Eeneral understanding of the term " Hands-On Operati ng 4 Experience" is that the way you put it --
5 q Yes?
6 A ---is supplied by the training that we go through to 7 become Reactor Operators and Senior Reactor Operators.
8 4 What is your personal level of experience in the oper-9 ation of a nuclear station?
10 A As a matter of fact, I've explained that earlier when 11 you asked me about the background that I had at Oconee.
12 4 There are persons who have served at nuclear stations i
13 who, you would agree, would you not, whose experience is not 14 charactericed as Hands-On Operating Experience ?
15 A Certainly engineers, I imagine.
16 Q Those that work in the front office of the plant and 17 not obtaining revelent experience in the actual operation of 18 the facilities, wouldn't you agree?
19 A Oh, yes.
20 4 Let's use your work history as an example. In your 21 judgement, what of your work experience represents " Hands-On 22 Operating Experience at a nuclear oower plant?
23 A Whtt experience do I have that represents Hands-On 24 Operating Experience?
25 4 Yes.
avatvu samaan associates. sta~orvea =aroarino sanv.ca cuanterra wo=rw camouma
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en,erc _ n;7, + ,n t, A I can tell you the positions that I've held that would ,
2 I think, that would supply Hands-Cn Operating Experience.
3 4 Yes, that is what I would like, please.
4 A Nucicar Equipment Operator, I've held that position.
5 It wasn't called that at that time, Utilities Operator.
6 4 What does a Nuclear Equipment Operator do?
A Operates the equipment in the plant.
8 4 Outside the Control Room?
A Outside the Control Room.
10 4 And you characterize that as Hands-On Operating Exper-11 ience?
A That's right.
13 4 Other pcsitions?
14 A Assistant Control Room Operator.
15 4 And what are the duties of an Assistant Control Room 16 Operator?
17 A Actually operating the Control Room.
18 4 In the nuclear power plant?
19 A That 's right.
90
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4 And what capacity; Is he an assistant as opposed to 21 an actual Control Room Operator?
~.m A He takes directions from the Control Room Operator.
93 He holds a license and actually manipulates the controls.
24 4 All right, other j obs?
25 L Cent ~oi Room Operntc~.
EVELvN DERGE R ASSOct4TES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTH CAROUN A J
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. GRAVES - Diract -
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4 What are the duties of a Control Rocm Operator?
2 A He directs the operations and assists the Assistant 3
Control Room Operator in the operation of the plant from the 4
Ocntrol Room.
5 Q Does he actually manipulate the controls?
6 A Yes, he does.
7 4 Other positions?
8 A Assistant Shift Supervisor.
9 4 Yes, what .are the duties of that job?
10 A He directs the Control Room Operators and the Nuclear 11 Squipment Operators out in the plant as well.
12 4 The Shift Supervisor, what are his duties?
13 A His duty is to direct the Assistant Shift Supervisor 14 on his unit and also to direct the Control Room Operators when 15 the Assistant Shift Supervisor is not present.
16 4 Does the Shift Supervisor manipulate the controls?
17 A He directs the manipulation of the controls.
18 4 I may have asked you this, but what would your answer 19 be to that question for the Assistant Shift Supervisor?
20 A He directs the manipulations of the controls.
21 4 He does not, himself, manipulate?
22 A He does not normally.
23 Q Again, the Assistant Shift Supervisor, is he licensed 24 to manipulate the controls?
25 a vn-EVELYN BERGE R ASSOCIATES. STENOTYPE REPORTING SERVICE. CHARLOTTE. NORTM CAROUNA L_
r~ .
- . GRAVES - Diract 12 I
g 4 And the Shift Supervisor as well is licensed to operat e 2
and manipulate the controls?
~
3 A Yes.
4 4 Any other jobs; I'm talking about your experience now?
5 g 7,ve h'ad other jobs , but it wouldn't be related to 6
Hands-On Experience, more management.
I 4 So is that the last position that represents Hands-On 8
Experience?
9
. A Yes.
10 Q All right, sir. As you define Hands-On Experience, or II as we have discussed Hands-On Experience, help me understand 12 what the actual, your personal actual experience of that sort, I3 has been in terms of time.
I4 Go back through this list and give me the time, say 15 time in these positions that you have held that we could count 16 as Hands-On Experience. Nuclear Equipment Operator, how long 17 did you perform that work?
I8 A I don't really understand Would you repeat your 19 question again?
90 4 Sure; 30u've related these as work that you have 91 performed that represents Hands-On Operating Experience. I'm trying to understand how much time you held in each of these oa positions to get a feel for a measure of your experience of o4 that sort in time; and in that light, how much time as a Nuclear 03 Eouipment Operator?
FVELYN SERGER ASSOC?ATEa. STENO ***E REPORTING SERVICE. CMARLOTTE. NORTH CAROUNA
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. chivvn-n4---* < ,2 i A If it is in writing here that will help (indicating). ,
2 MR. Mc3ARRY: It is all in writing on table .
3 13 1 3-i on Page Sixteen.
BY MR. GUILD:
4 Now I am looking at that table. Counsel helped me 6
with the first position that is shown under experience, two 7
years; Utilities Operator: Is that the Nuclear Equipment Opera-8 tor position that you had reference to?
9 A Yes.
10 4 That is what it was called at that time?
11 A Yes.
12 4 So just two years in that position; and Assistant 13 Control Room Operator, how much time?
14 A One year.
15 4 Control Room Operator?
16 A One and one-half years.
17 Q Assistant Shift Supervisor?
18 A One and one-half years.
19 4 And the Shift Supervisor?
20 A Two and a-half rears.
21 Q That adds up to eight and a-half years all total.
22 Would you agree that the first two years as a Nuclear Equipment 23 Operator, your experience was not in the manipulation of the 24 controls of the reactor, itself?
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1 4 That is true; l'.r. Graves, have you participated in 2
my company efforts or industry efforts to change or produce new 3
3tandards for the experience and qualifications of nuclear power 4
plant Reactor Operators?
5 A Not to my knowledge.
6 4 You did not serve on any industry committees or task 7
Forces that are working on --
8 A Not in the training area.
9 4 How about in the operations area?
10 A No, I participate in some seminars at IMPO meetings ,
11 but that is it.
12 4 Are you familiar with the position of the company in 13 recommending standards for training and qualifications of reactor 14 operators?
15 A I'm familiar with ASMI Standards.
16 4 Are you familiar with the American National Standards 17 prom.ulgated by the American National Standards Institute for 18 experience qualifications and training of personnel for nuclear 19 power plants?
20 A Yes.
21 4 ANSI eighty-one? '
22 A Yes.
23 4 I am trying to refer to a section of the ANSI Standard 24 here; Page 15 of my copy of the 1981 ANSI Standard under the por--
25
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GRAVES - Direct -
15 1
tion functions that come under the heading of "On-the-Job Train-2 ing".
3 Eave you seen that section?
4 A Yes, I have.
5 4 In you'r opinion, Mr. Graves, do those enumerated 6 functions represent the significant operating responsibilites 7
which are reflected under the term " control nanipulations rel-8 ative to the operation of a nuclear power plant"?
9 A I don't really understand'the question. Can you repeat 10 that?
11 4 The list of functions that you see listed there, are 12 those in your opinion a complete and accurate representation of 13 the important functions performed by Control Room Operators at 14 a nuclear power plant?
15 A Okay, Bob, let me say first of all, do you understand 16 that the NRC has not adopted this NC Standard?
17 4 Yes.
18 And this is On-the-Job Training und most all of this A
19 would be performed on a simulated -- not in a plant -- and I 20 understood your question to be in a plant?
21 4 Yes, What I want to understand, Mr. Graves, is your 22 opinion about that list as a complete and accurate representation 23 of the significant functions that a Control Room Operator must 24 perform competently in a nuclear power plant.
25 Our training covers the items that A I can say this:
EVELYN BERGER ASSOCIATES. STENGTYPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA l
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1 are listed here.
2 4 I s.m not trying to trick you; I am trying to under-3 stand.
4 A I understand, I just wanted to understand your ques-5 tion.
6 4 Back to my question, are there any significant res-7 pensibilities that are not included in this list that you think 8
are significant to safe operations of a plant?
9 A No, I think that is a comprehensive list.
10 Are there any items on that list in the NC Standard 4
11 that, in your judgement , are not significant to the safe opera-12 tion of a plant?
13 Some of them are less sig-A That is a hard question.
14 nificant than others.
15 Q Well, significance I want to understand in the sense 16 of them being skills that you believe it is important for some-I l
II one to have in order to perform their function competently in 18 the operation of a nuclear power plant.
19 So take a moment and look at the list, and if there l
i 20 are any items on there that you do not believe fit that descrip-t 2I tion, I would be interested in your opinion as to their identity .
22 A They are all good items to train.
t l
23 4 In your opinion should persons who are responsible 24 fcr manipulating the controls at - Catauba Station all have er.-
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rerience in the functions that are set forth in that Standard?
EVELYN EERGER ASSOCIATES. STENOTYPE REPORTING $ERVICE. CHARLOTTE. NORTH CAROLINA
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, GilAVES - Direct -
17 1 A Yes. '
2 4 And speaking of this list of 27 items -- t 3 A Yes. -
i 4 4 You said a moment ago, Mr. Graves, that these items, 5
or many of these items, that experience in those items is provid ed 6 through work on simulators.
7 A (The witness nodded his head affirmatively.) Yes; 8 :' hat is true.
9 4 Is that part of Duke's training program, to provide 10 cIperience in those skills on simulators, on a simulator?
11 A On simulators or previous operating experience.
12 4 What I want to understand is your opinion about the 13 relationship between simulator experience and actual operating 14 experience, Mr. Graves. Do you believe they are equivalent?
15 A Yes.
16 4 All right, sir; what simulator is employed for providir g 17 '
- his experience for Catawba operating room personnel, or , McGuire 18 n iculator at the McGuire site? I was trying to understand the 19 company's position in some correspondence which I don't have in I
20 front of me with the NRC. Does the Cc= mission recognize testinE ,
21 training and experience on McGuire simulators as equivalent to 22 .such testing, training and cIperience at the actual Catawba 23 Control Room?
24 A As far as I know, yes. Can I say something additional 25 on that?
EVELYN SERGER ASSOCtATES. STENOTYPE REPORTING SERvtCE. CMARLOTTE. NORTM CAROLf%A
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. GRAVES - Dirnet 18 I
4 Certainly.
2 A The cold certification training, the program has been 3 ~
approved for both Catawba and McGuire on the McGuire simulators ;
that is what I was referring to.
5 4 When was that approval made, Mr. Graves; Do you recall?
6 A I don't really recall.
7 4 Recently?
8 A The initial program was approved I think in 1977 4 I really am not clear about this, and maybe you can 10 help me understand it. Is there a recent decision or request 11 to the NRC for some reliance en the McGuire simulator for test-I ing purposes for Catauba operators?
I3 Do you have any idea what I'm referring to?
" I don't understand your question.
A 15 4 All right, are there some pending positions by Duke 16 seeking approval by the NRC for use of the McGuire simulator i 17 .
l to test Catawba operators?
, 18 l A Yes -- I really don't know what you are referring to.
t l 19 Could you be more specific and maybe I could answer your ques-l l 20 tion.
21 4 Okay, lets see if I can find the reference. I have a
, no
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piece of correspondence, Mr, Graves, that is dated January 31,.
os l 1983 (indicating) from Mr. Tucker of Duke to Mr. Denton of the B
24 NRC; and it references a cold license certification program, i 25 and let mc ash if y0u haic CCen that beforc?
l EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERveCE. CMARLOTTE. NORN CAROUNA l
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1 A Yes, I have.
2 I think what I had reference to was en the paragraph, 4
3 this is an attachuent to that letter under the heading " Training 4
for Mitigating Core Damage".
5 Under the background section it says at the bottom, 6
"As early as 1978 Catawba Nuclear station requested a waiver of 7 simulator examination on the McGuire simulator as part of the 8
licensing process."
9 A Yes.
10 4 Can you explain that to me?
Il A It was in reference to actual licensing on the McGuire 12 simulator. Request was made to actually license on the Catawba 13 Station rather than the McGuire simulator.
14 4 What happened with that request?
15 A It was approved as far as I know.
16 4 Help me understand what that means, persons who would II be licensed to operate the Catawba facility would be tested on I8 the basis of operation of the McGuire simulator; is that correct?
l9 This asked not to be licensed on the basis of testing A
l 20 on the McGuire simulator.
2I Q But instead on the actual Catawba --
l ~
22 A Actual Catawba Plant.
23 4 Why would the NRC have asked you to test Catawba op-
.n erators on the McGuire simulator?
23 L The thinking was that the McGuire simulator was EVELvN SERGER ASSOCIATES. STENOTTPE REPORTihG SERVICE. CHARLOTTE, NORTH CAROUNA
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- n-,--n _ ,, -.x gg I d dentical to the Catawba Plant, and there was actually come 2
differences. Rather than learn both the McGuire Plant and the 3
Catawba Plant, wb'thcught it would be advantagocus and have better, 4
more applicable training, to train more on Catauba than actually 5
train the Cataw'ba personnel on learning how to operate the 6
simulator with these differences.
7 4 The last page of the correspondence, Mr. Graves, 8 "Some simulator training reflects the following observations:
8 allowing candidates to make retetivity changes, observe, analyze, 10 and take corrective action en celected malfunctions.
II "Centrol board and procedural differences will not I2 allow actuni implementatien of Catawba Huclear Station procedures I3 on the McGuire simulator, but transient responses will be the I4 simulator at Catawba. "
15 What are the Catawba Nuclear Station's procedures -
16 that can't be actually inplemented on the simulator?
17 A One that comes to mind --
18 4 The important ones?
A One that comes to mind is the t"5bine radiator start-20 up.
91 4 Can't that be simulated effectively?
oo
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A Different manufacturer. .
o3 What are the differences 7 4
44 A One, McG uire is Westinchouse tanufactur ed and Catawba 25
<1s General Electric.
EVELYN SERGE R ASSOCIATES. STENOTTPE REPORTING SERvlCE. CHARLOTTE. NORTM CAROUNA
. nervre _ p4ppe+ --
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4 I want to direct your attention to Page 29 of the 2 follow-up responses to follow-up interrogatories that ask 3
about the differences between the Catawba and McGuire simulator ,
4 Catawba Plant and McGuire simulator; does it not?
5 A Right.
6 4 Do you agree those represent the significant differences 7 between the two?
8 A I would say yes.
9 4 Describe for me generally, Mr. Graves, the testing to procedure, as the word is employed, by Duke for persons who 11 ultimately will be licensed to operate the Catawba Control Room .
12 A Do you want me to tell you how the people are tested?
13 4 Yes, sir.
14 A During the program they are tested. As a matter 15 of fact, I think it is in the NSAR here that describes the test -
16 ing program.
17 4 Please refer to it if there is a section.
18 A If I can find it, I can't see a section here that re-19 fers directly to it; but there are weekly tests given, quizzes 20 in-between.
2I Run me through the testing procedure that leads up to Q
22 soneone being licensed to perform Control Room Operator functicis ,
23 Mr. Graves.
24 A Like I mentioned, at the end of each week there is 25 an examination given that covers the material for the entire EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SE RVICE. CHARLOTTE. NORTH CAROUNA
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. NRAVES - Direct 99 I
week. Each day there is a qui:: given after the presentations 2
are made.
3 At the end of the entire training program there is 4
an overall evaluation made from an outside vendor or either 5
training personnel from another utility to evaluate the know-6 ledge level of the personnel.
4 Who are the "outside vendors" that you are referring to?
9 A It can be the Carolina Power and Light or it could be IU another vendor.
II 4 Another utility operator, is that what you are referring 12 t09 I3 A Training personnel from other companies.
I4 4 Not a contracted man that comes in to do this?
15 A My experience is it has been people from other utilities.
16 4 These are. sort of course work qui::zes; The term " quiz, "
17 was used in response to some answers to interrogatories; things I
that an instructor would give in the normal course of presentinE:
I9 instruction to candidates for operator licenses; is that right?
00 A Like I mentioned, the quizzes are given on a daily basis, I
of
- I and the examinations are given at the end of the week or ence a 44
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week. _
43 4 What kind of other tccting is given to candidates for 44 Control Rocm positions?
23 A T believe At in d a r a i h ~* ke e 5 the relcet'en Trc-ccct EVELYN BERGER A$$0CIATES. STENOTYPE PEPORTING $ERVICE. CHARLOTTE. NORTH CAROUNA
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. nwaven ni-pet .
23 1 in one of our interrogatories.
2 4 If you would like to refer to it, that is fine i other-3 wise to the best of your recollection.
4 A Here it is, Page 31 on " description," it has the test 5 that is given.
6 4 These are the pre-employment tests that are referred 7 to here?
8 A Right.
9 4 And there is a psychological test that is given?
10 A Right. I aight mention, too,'there are oral examina-11 tions given periodically during the program as well.
12 MR. CARR: Excuse me, Counsel; I might chow the 13 witness a couple further answers to interrogatories.
14 MR. GUILD: Sure, if it would be helpful.
15 16 BY MR. GUILD:
17 4 How about if you would identify those other answers 18 that right help us?
19 A Interrogatory Number 34 on Page 24.
20 MR. CARR: That is in response of September 22, 21 MR. GUILD: Is there anything else?
22 THE WITNESS: There is some more information on 23 Interrogatory 35, Page 53 24 MR. CARR: And that is the response of February 28 of 1989.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SERV 4CE. CMARLOTTE. NORTM CAROUNA
ORAVES - Direct 24 1 MR. CARR: That is in responce of Septenber 22.
2 MR. GUILD: Is there anything else?
3 THE WITNESS: There is cone tore information on 4 Interrogatory 35, Page 53 5 MR. CARR: And that is the response of February 6 28 of 1983 7
8 BY MR. GUILD:
9 4 Is there a test that is administered controlling per-10 sonnel by the Nuclear Regulatory Cornission?
11 A Yes, there is. -
12 4 What does that test consist of?
4 13 A Of course, it has not.been adninistered for the Cat-14 awba personnel yet.
15 [Thereupon, an unidentified person entered the Deposi.-
16 tion Room and the following procedings took place:]
l l
17 MR. McGARRY: Can we put on the Record who is in I
18 attendance?
19 IG. GUILD: Yes.
20 MR. McGARRY: I think we reflected at the begin-21 .
ning the people in attendance at this necting with 22 the people in attendance in previous Depositions with
! 23 two excertions.
l 24 MR. GUILD: One is Jesse Riley andBetsy Leviticas.
l 25 MR. McGARRY: That is fine.
EVELYN BERGER AS$0CIATES. STENOTYPE REPORTtNG SEPViCE. CHAR.OTTE. NORTM CA AOLINA
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GRAVES - Direct .
25 l
1 BY MR. GUILD:
2 4 Now then, the NRC's Tests --
3 L It is a comprehensive examination that covers several 4 areas: Mainten'ance, Operation Systems, Reactor Theory, Thermo-5 dynamics, Instrumentation, Fuel Handling, and several other 6
areas that I can't really recall right now.
7 4 And this examination is given to qualified people to 8
perform what functions, Mr. Graves?
9 L To be Reactor Operators or Senior Reactor Operators.
10 4 Same test for both?
11 L Ho, the test is different.
12 4 Uhen would this test be administered or these tests 13 be administered for Catawba personnel?
14 L Shortly before fuel loading.
15 4 When is the testing planned?
16 A The testing is planned for March of next year.
17 l 4 19847 18 A Yes, sir.
19 4 Are there other tes'st for Catawba, other examinations 20 for Catawba operating perscnnel that are administered?
21 A Not that I an recall other than those that I've al-l
~
22 ready pointed out.
3 4 All right, the NRC administers one test that is the l
1 24 axamination that you have referred to that wculd take place in l
28 March of 1984, one for each Reactor Operator and Senior Peactor EbELvN BERGER ASSOCIATES. STENOTvPE REPORTING SE RytCE. CMARLOTTE, NORT*e C AROUNA
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, GRAVES - Dirset 26 1 Operator?
2 A One uritten test for Senior Reactor Operctor and Re-3 actor Operator, and a written test and oral examination.
4 Q Describe the oral examination, if you would, Mr. Graves.
5 A The oral examination can take place, it is either four 6
to Six hours long; and it is basically a sit-down session askin g 7
questions about the plant operation, emergency procedures, acci -
8 dent analysis questions.
9 Then it is a walk-thru th'e station continuing to ask 10 oral questions. And part of that time is spent in the Control 11 Room on the Control Room panels quitting the operators to find 12 out their understanding of the plant.
13 Q Who would administer that oral exam?
14 A The NRC.
15 4 Do you know who from the NRC7 16 A No, I don't.
II 4 Can you describe generally the positions of the peopl e 18 who would administer those exams?
19 A They are from the NRC; I don't, I'm not familiar with 20 individuals that are giving them or their background.
21 4 Or their specific titles or areas?
22 A No; as a matter of fact, they reorganized that parti ,
23 cular section in NRC, and it is a little confusing at this time 24 as to what their titles are and what they are called.
25 4 How many persons do you anticinate takinr the "FC's EVELYN BERGER ASSOCaATES. STENOTYPE REPORTING SERelCE. CHARLOTTE. NORTH CapOLsNA
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. GRAVES - Diract
. . 27 I written and oral examinations, either ac Reactor Operators or 2 Senior Reactor Operators for Catawba?
3 A Actually around 50 to 55.
4 4 Total?
5 A Total.
6 4 How many of those would be taking the SRO and how 7 many the RO tests?
8 A I don't really recall, probably about half.
9 4 Half of each?
10 A That is a ballpark number.
11 4 Those who take the Senior Reactor Operator exam, they 12 will hold a license as Reactor Operator?
13 A Some will have held licenses as Reactor Operators, 14 and some will not have held licenses as Reactor Operators.
15 4 From the half that would be taking the SRO, can you 16 give me an approximation how nany of those half SRO candidates 17 would have RO licenses?
18 A Gee whic, roughly half.
19 Q And those have held'SRO licenses previously?
20 A Those have held RO licenses previously.
21 Q Those have held SRO licenses previously?
l 22 A RO licenses previously.
l 23 4 l I am confused; of the 50, half of those vill be taking 24 the SRO exam?
25 A Right.
EVELYN SENGER ASSOCIATES STE%OTYPE REPCstTfhG SERVICE. CHARLOTTE. NORTH CAROLINA
7, .
. BRAVES - Direct 28 1 4 And half of those, say ten or 15, would hold an SRO 2 license?
3 A Or RO license.
4 4 But not at Catawba?
5 A Not at Catawba.
6 4 I understand you will use you, yourself, as an example?
7 A For exanple, I have been previously licensed as an 8 SRO at Oconeo.
9 4 And you will take the SRO license at Catawba?
10 A I intend to.
11 4 Of the half who will be taking the SRO licenses, how 12 many of those already hold SRO licences at another facility?
13 A Repeat that again, I'm sorry.
14 0. Okay, you have about 20 to 25 people, approximately, 15 who will be taking the Senior Reactor Operator Exam in March '847 16 A Right.
17 4 Sone of those have previous licenses?
18 A Right.
19 Q Row many of those do you figure will have already been 20 licensed elsewhere as Senior Feactor Operators?
21 A Roughly half.
22 4 About 157 23 A Possibly.
24 Ten, 15, comething like that?
Q 25 A I don't have the exact figures in fron of me.
EVELYN SERGER ASSOCIATES. STENOTYPE REPORTING SE Rb tCE. CHARLOTTE. NORTH CAROUNA
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29 Q Will any of the candidates for Reactor Operator licens es already hold Reactor Operator licenses for other facilities?
3 A No. -
4 Q Let ne see if I follow this now: Will any of the can-5 didates for Senior Reactor Operators at Catawba hold a license as 6 a Reactor Operator at another facility?
7 A A few.
8 Q Can you give ne an estimate of how man." that would be?
9 A I recall tWo.
10 Q Do you agree that a person can hold Reactor Operator, 11 Senior Reactor Operator licenses without having significant 12 actual operating experience at a large pressuriced water reactor?
13 A I really don't know what you mean by "significant."
14 Q You interpret the term as in your judsenent it should 15 be interpreted, Mr. Graves; significance in performing the func-4 16 bion of rmnning a nuclear reactor.
17 A And your question again?
18 Q The question is, let me reconstruct it: Persons can 19 be licensed and can hold a license as a Reactor Operator or 20 Senior Reactor Operator without having had significant actual 21 dands-on operating experience?
A 22 Our training progran provides adequate experience for 23 in individual to hold an RO or Senior Reactor Operators license.
24 Q I am asking the converse of that; lay aside Duke's 25 program. Would you agree one could get a license as a Reactor EVELYN BE RGER ASSOCIATE S. ETkNOTTPE REPORTING SERVICE. CMamLOTTE NORTM CAMOUNA
. GRAVES - Direct 30 f
1 3perator or Senior Reactor Operator without having a previous 2 license?
3 MR McGARRY: I believe the question has been 4 asked and answered; and he said that Duke Power pro-5 vides the actual training for one to sit before an RO 6 or SRO.
7 MR. GUILD: I appreciate Counsel's view, but I 8 would like the question answered.
9 THE WITNESS: I would have to see what training to the individual had Eone through before I could say 11 that he had significant operating experience or he did 12 not have significant operating experience.
13 You would have to.give me a specific example and 14 I could tell you yes, he has the operating experience; 15 or.ao, he doesn't.
16 17 BY MR. GUILD:' -
18 4 That is the point of the question: Just having a 19 ticket to run a plant does not mean you actually have that ex-20 perience?
21 A That is a fair statenent, and I would like to say that 22 our training prograns are really designed for the individual to 23 thoroughly understand and operate the plant and actually the 24 licensing is a subset of an overall training program.
i I 25 4 Wouldn't you agree just being licensed doesn't emr~ ...or. .ssociares. sr ~orv, as, car,~a s vice. c~morra. ~ oar ~ c. ou~.
i
m GRAVES - Direct ..
31 1
guarantee the adequate training or experience to operate a plant ?
2 A I can't say that because I've neter been involved in 3
any other utility' training programs. I have only been exposed 4
to Duke Prograns, so I can't answer in relationship to Duke's 5
programs.
6 They are. Ei ven the adequate experience to operate the 7
station.
8 4 Lay aside the specifics of Catawba or Duke. It is true, 9
, is it not, Mr. Graves, that acteone 'can be licensed as a Senior 10 Reactor Operator and work in the front office and push paper?
II A That is true.
12 C It is true comeone can hold a Reactor Operators Licens e s
13 for a period of time, perhaps years, and work in the front offic-e 14 and push paper?
15 A In ' order to' hold that operators license he has to go 16 through' a periodic qualification program to prove his competence 17 to operate the controls. .
i 18 Q Is that requalification progrms in your judgement either 19 l a subsititue for or equiv21ent to actual control room experience?
90
~
l A I think the program is vamped, is designed such that 21 the individual can etintain his qualifications.
22 Q I.re there minimum levels of actuni hands-on operating 23
>::perience that Duke Power requires of its Control Room operating 24
':ersonnel; and if co, would you tell ne >: hat they are?
" ,t rh e - n c rinimum trr4ning ranu*-a-anen ena kan tn maat I
avetv~ ...oea associavas. su~orves arroamo 5:av'ca ca^"'ot'E "o"'" c^" "*
P GRAVES - Direct 32 1 in order to stand for a license; and within that encotpasses 2 the minimum hands-on experience that you have referred to.
3 4 Back out of all of that training, Mr. Graves; the 4 specific portions of that qualification which is hands-on operat -
5 ing experience, what is the minimum hands-on operating experienc e 6 that would be required of Catawba Control Room personnel?
7 A It is the experience that is really defined in the a training programs.
9 4 Help me find that, I want' to focus on that ene aspect 10 of it, if I can.
11 MR. McGARRY: I would like the Record to reflect 12 perhaps a potential miscommunication in the use of the 13 term " Hands-On Operating Experience."
14 As I understand your use of it, you mean physically 15 working the controls, and I've heard Mr. Graves say on 16 at least two occasions it is comprised of the training 17 program of Duke Power Conpany.
18 MR. GUILD: Mr. Graves, I appreciate your Counsel 19 try to clarify that.' 7 think I understood your answern 20 as you gave them.
21 22 BY MR. GUILD: '
23 4 Is there any minimum actual br.nds-on operating experi-24 ::nce required of Catawba Control Room personnel?
25 A The entire field, like I stated earlier, the require-EVELYN SERGER ASSOCIATES. STENOTYPE REPCPTING SE RytCE. CHARLOTTE. NORTH CAROLIN A
F- e i
GRAVES - Diract . 33 1 cents that are set forth in the training program, an individual 2 has to pass the training program before he can stand for a lic-3 ense; and that is all designed within our qualifications, opera-4 tive qualificatiens and training prograns.
5 4 Is there a requirement for a minimum amount of time 6 actually operating a large pressurized water reactor in order to 7 be licenced and qualified by Duke to operate the Catawba reactor?
8 A Let me understand your question: You said is there a 9 r.inimum amount of time required to operate an actual pressurized 10 water reactor in order to get a license at Catawba?
11 4 Yes.
12 A No, I don't know of any minitum amount of tine.
13 4 Is there any minimum hands-on operating experience to 14 be required by Duke before one can hold the position of Senior 15 Operator at Catawba?
16 A That is encompassed in our training program, and when 17 the individual sucessfully completes our training program he 18 stands for a license with the NRC.
19 4 What is that minimum operating experience required of 20 Senior Reactor Operators at Catawba?
21 A It is defined in the FSAR in 13 2.
22 4 I am looking for a number, and if a number exists, Mr.
23 Graves --
24 MR. ficGARRY: I would like the Record to reflect 25 we continue to be confused in this area. Mr. Guild, EVELYN SERGER ASSOCIATE S. STENOTYPE REPORTING SERVICE. CHARLOTTE. NmrTM CARouka
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GEAVES - Direct 34 1
You are looking for a specific period of tine where 2
people are noving valves and turning knobs by your use 3
of " Hands-On Operating Experience."
4 About four times Mr. Graves has answered questions 5
concerning Hands-On Operating Experience in the sense 6
of the complete training program; and if this will
- continue, I will direct the witness not to answer 8
these questions any further.
9 MR. GUILD: Are you doing that now?
io MR. McGARRY: I am not doing it at this particular -
11 time.
12 THE WITNESS: It is in Section 13 2 under para-13 graph 13 2.2.2.2, "Fornal Job Training."
14 15 3Y MR. GUILD:
la 4 And how much experience is set forth there?
17 A The. training progrma defined here is from 16 to 18 is weeks.
ig 4 That is training?
20 A That's right.
21 4 I'n asking about actual manipulations of controls-in 22 the power plant, actual operating experience. .
23 A FSAR does not give a nunber on cinulator training.
24 4 I'm sorry, ' docs not give a number"?
25 A. Wnat was your question again; I'm corry?
EVELTN BE.RGER ASSOCI ATES STENOTYPE REPORTING SE RvlCE. CHARLOTTE. NORTM CAROLIN A
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. G' RAVES - Direct - 2R
, 1 4 Actual operating experience, in there a standard estab-2 liched that you were lookinc for in the FSAR. actual operating 3 experience. .
4 A I was 1 coking under sinulator portien of the training S procram.
6 4 Not a simulatcr, actual experience?
7 A This section defines the experience level of Reactor 8 Operators and Shift Supervisors. It states that experience 9 levels are required in that particular section.
10 Q I think it is 13 1.: -Let me direct your attention to 11 In Answer to Interrogatories. Mr. Graves, I have Interrogatory 12 three in a response by the company of September 22nd.
13 It refers to FSAR Section 13.2. Is that what you hap-14 cened to find there?
15 A Yeah, I have the experience levels as stated in 13.1.
16 4 You try what you have there and we will see if it five s.
17 A All right, let me look over this a second. It is unde:r 18 L3 1 3, "cualifications of Station Personnel."
19 0 !as.
20 t " hose qualifications are in accordance with Section 21 'our of ANSI 18.1, 1971, " Selection and Training of Nuclear 22 ')ower Plant Personnel." And under 13.1.1.3.1, " Minimum Qualificai 23 ; ion Requirenents," that vocaks about operators.
24 Would you like for me to read that?
25 4 If you would refer to that ANSI, if there is something EVELYN BERGER ASSOC ATES. STENCTT PE REPORTsNG SE nvlCE. CHARLOTTE. h0RTH CAROLINA
f~ .
. r,R a ves n4 w n+. og 1 in there that sets a mininum hands-on operatinc experience re-2 quirement for qualifications. cf operators at Catawba, that is 3 the information I'.m lookinC for.
4 A This speaks to experience.
5 4 Does it define in any part of that experience a require-6 T.ent for actual hands-on operating experience?
7 A It does not speak to actual hands-on operating experi-8 ence.
9 4 How about other personnel?'
10 A The Shift Supervisor and Assistant Shift Supervisor, 11 his experience and cualifications.
12 4 Moving up the chain of command, the next above him 13 '
rould be the Assistant Shift Supervisor?
14 A' Yes.
15 4 'r? hat is the actual hands-on experience for an Assistant 16 l3hift Supervisor?
17 A The Assistant Shift Supervisor, a year and a-half to 18 neet the same experience.
19 4 That is --
20 A "An Operating Engineer shall have a minimum of a high 21 school diploma, or equivalent, and four years of responsible
- 1uelcar or fossile station eEperience, of which a minimun of 22 23 pne year shall be nuclear station experience."
24 "A maximum of two years of the remaining three years 25 of experience may be fulfilled by academic or related technical EVELYN SE RGE R ASSOCIATE S. STENOTV"E REPORTING SERvtCE. CHARLOTTE. NORTH CAROUNA
'0 RAVES - Direct -
1 training on a one for one, timo basis."
2 "An Operating Engineer shall hold a Senior Reactor 3 Oper.ator Licence."
4 4 Let me see if we agree. On Answer Three, Answer to 5 Interrogatory Three, do you have that in front of you? That 6 is available to you, Mr. Graves?
7 A (The witness nodded his head affirmatively.)
8 Q Uould you state yes or no; is that available to you?
0 A Yes, it is.
10 There, I'm looking at Page 14 ; I'm looking at the 4
11 sentence that says, "In order to sit for the examination to be 12 licensed by the NRC as a Reactor Operator in the Catawba Contrc 1 13 Room, an individual must have at least two years of nuclear or 14 fossile station experience, of which a minimum of one year shall 15 be nuclear station experience."
16 "In order to sit for the examination to be licensed by 17 the NRC as Senior Reactor Operator, an individual must have 18 four years of responsible power plant experience, of which no 19 more than two years will be ' academic or related technical train -
20 ing."
21 "Two years will be nuclear power plant experience, of 22 which at least six months w'ill be at Catawba." Is that accurate?
~
23 Now which is the accurate statenent.for the experience recuire-24 nents?
20 The FSAR conflicts on that point.
L EVELYN BERGER ASSOC:ATES. STEh0 TYPE RE PORTING SERyiCE. CMARLOTTE. NORTH CAROLINA
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, ' GRAVES - Direct 38 1 Q Which is accurate? Which is accurate in Section 13.17 2 A (Indicating) That is inaccurate.
3 4 That is. inaccurate?
4 A It Ehculd be corrected to read one year.
5 4 One year; now for the Record, that is Answer to Inter-6 rogatory Number Three of Applicants- Response to the second set 7 of Interrogatories and Request to Produce dated September 22, 8 1982-9 Now define, if you will, Mr. Graves, the one year nuc-10 1 ear power plant experience which is required under the provision.
11 A That is defined in ANSI 18.1.
12 4 Yes, do you have that in front of you or available to 13 you?
14 A No.
15 4 Can you tell ne what your understanding of the defini-16 tion of that term is?
17 A As I recall, nuclear operator experience is that ex-18 perience, is that Eained in the construction, design, pre-opera -
19 tional testing and start-up of a nuclear power plant.
20 4 Is that nuclear power plant experience then required t 3 21 be actual hands-on operating experience of a nuclear power plan b?
A 22 The way that the Standard reads, it could be some of 23 either.
l 24 4 Uell, the way the standard reads it could be billing 25 forms on the job site, couldn't it?
EVELYN BE RGER ASSOCl4TE S. STENOTYPE REPORTING SERvtCE CH ARLOTTE. NORTH C AROLIN A
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00 1 A It is not interpreted that way.
2 C Eut it could be, isn't that so?
3 A It could be hypothetically.
4 O Does Duke define that term in a fashion that would 5 exclude non-hands-on operating experience from that requirement?
6 A Our training prograns are designed to provide adequate 7 experience to maintain Reactor Operator.and Senior Ecactor Op-8 erators license that really excludes -- but it provides for the 9 experienced and non-experienced operators.
10 Q I understand your opinion, Mr. Graves, but what I'm 11 trying to focus on is the narrow question of how Duke interprets 12 the experience of one year in order to stand for an SRO exam 13 or to be licensed as a Shift Supervisor or Assistant Shift 14 Supervisor or an Engineer.
15 And I'm not clear what kind of nuclear power plant 16 experience do you mean by that term?
17 Let me answer it this way: It is not Duke Policy A
18 to bring in an individual from the outside as a Shift Super-19 All our people are brought in as learners and go through visor.
20 the programs that are designed to bring them up to the level of 21 Reactor Operator or Senior Reactor Operator.
22 They cone in as learners and advarae to Nuclear Equip-23 ment Operators and through the line to Shift Operator and so 24 forth, Assistant Shift Supervisor.
25 g yeg, 317, EVELYN BERGER ASSOCIATES. STENO TYPE REPORTING SERvlCE. CHARLOTTE. hCRTH CA*tOLIP*A I
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CRAVES - Direct 40 3
A So that provides them with the adequate experience and 2
training in order to function in general.
3 4 Is there a policy, written statement, that reflects 4
the policy that you just outlined?
5 A Not as.I know of.
6 Q Is there any written policy that you know of, Mr. Graves, 7 that would for Duke Pcwer Company define that nuclear power 8 plant experience requirement to be specifically Control Room 9 operating experience?
io A Not as I know of.
11 4 Do'you know whether or not all Catawba personnel who 12 are to be credited with the one year nuclear power plant experi-13 ence have.had at least that one. year as actual Control Room op-14 erating experience?
15 A Some of those individuals will have experience at the 16 McGuire Station and/or the Oconee Nuclear Station; and some will 17 gain experience.
is Of course, they have been gaining experience in the ig check-out and start-up and the pre-cheel -out phase of Catawba.
20 4 Is the answer No?
21 A I" the answer No?
22 4 To the question. ,
23 A The ancwcr is those individuals will have experience 24 at McGuire and Oconee.
rs 4 Actual hands-on experience?
EVELTN BE RGER ASSOCIATES. STENOTYPE REPORTING SE RvlCE. CHARLOTTE. NORTM C AROLINA
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41 1 A They have gone through on-the-job training at Oconce 2 and McGuire and have participated 114 the pre startup activities 3 at Catawba; so they have actual hands-on experience 4 . Actual hands-on experience, not necessarily.
5 Q During the pre startup stages at Catawba and McGuire --
6 A Yes, sir; actual hands-on operating experience; let 7 me give you an example: I was talking to one of my individuals g who just came back from McGuire yesterday.
9 He happened, as a matter of fact, he actually to performed one of the startups at McGuire, Unit Two.
11 Q Mr. Graves, are you aware of any other errors in the 12 Responses to Interrogatories on the subject of qualifications?
13 A I am not aware of any.
14 Q E.xcept with the area with regard to the one year 15 versus two years?
16 A (The Witness nodded his head affirmatively.)
37 Q Is that an affirmative answer?
A Yes.
18 gg MR. GUILD: Thank you; let me have about two minutes.
I am finished with Bill.
O 21 FURTHER THE DEPONENT SAITH NOT. l 22 23 24 25 EVELYN SERGE R ASSOCIATES. STENCTYPE 8tEPORTING SERVICE. CHARLOTTE. NORTM CAROLINA i
I a 4?
1 I, Clyde William Graves, hereby certify that I o
have read and understand the foregoing transcript and believe it to be a true,'rreurate and complcte transcript of my
~
3 4 testimony.
5 6
7 CLYDE WILLIAM GRAVES 8
9 10 11 This Deposition was signed in my presence by 12 Clyde William Graves on the day of June, 1983.
13 14 15 16 NOTARY PUBLIC 17 18 19 20 21 22 23
( 24 25 EVELYN BERGER ASSOCIATES. STENOTYPE REPORTING SERVICE CHARLOTTE, NORTH CAROUMA
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s e ,e 43
, 1 CERTIFICATE 2 STATE OF NORTH CAROLINA 3 COUh"L"I OF MECKLENBURG 4 I, Lynn B. Gilliam, Court Reporter and Notary Public, 5 do hereby certif that the foregoing deposition of Clyde 6 William Graves is a true, accurate and complete transcript 7 and that the proceedings were by De reduced to nachine shorthand 8 in the presence of the Witness, afterwards transcribed upon a 9 typewriter under my direction.
10 I further certify that this deposition was taken at 11 the time and place in the foregoing caption specified.
12 I further certify that I am not a relative, counsel 4
13 or attorney for either party or otherwise interested in the 14 outcome of this action.
15 IN WITNESS WHEREOF, I have hereunto set my hand at 16 Charlotte, North Carolina, on this the day of May, 17 1983.
~.
18 19 20 LYNN B. GILLIAM 21 Notary Public 22 23
' My Commission expires May 12, 1988.
24 25 EVELYN BERGER AS$OCIATES. $7ENOTYPE REPORTING SERVICE. CHARLOTTE, NORTM CARouhA